The investigation centred on the way the AA framed savings on breakdown cover, with the CMA concluding that aspects of its approach risked misleading customers. In particular, the regulator focused on whether the discounts being advertised genuinely reflected a meaningful saving against a true ‘’usual’’ price, and whether the overall presentation created a false impression of value.

This sits squarely within the CMA’s broader crackdown on pricing practices, especially where businesses use reference pricing, time-limited offers, or urgency cues that may not stand up to scrutiny. While these techniques are widely used across marketing, the CMA’s position is becoming increasingly clear: if a saving is claimed, it must be real, substantiated, and presented in a way that consumers can trust.

For the AA, the outcome is not just a regulatory slap on the wrist. Following the investigation by the Competition and Markets Authority, the business has been required not only to pay a financial penalty of £4.2million, but also to provide refunds to over 80,000 affected customers totalling £720,000. Crucially, the AA has also had to commit to changes in how it presents pricing and discounts going forward, ensuring that any future savings claims are based on genuine, substantiated reference prices.

Much of what the CMA has challenged in this case, strikethrough pricing, “was/now” comparisons, and limited-time framing, are staples of promotional campaigns. Whether it’s a gift-with-purchase mechanic positioned as added value, a member-exclusive discount, or a seasonal sales push, the same principles apply.

The key issue is substantiation. If a promotion claims a saving, that saving must be based on a price that has been genuinely charged for a sufficient period of time. If urgency is used, it must be real. And if an offer is framed as exclusive or time-limited, it cannot in practice be continuously available.

This is where the CMA’s approach intersects with the remit of the Advertising Standards Authority. While the ASA assesses whether marketing communications are misleading, the CMA is increasingly focused on the underlying commercial reality. Together, they create a more comprehensive enforcement landscape, one that looks at both what is said and whether it is true in practice.

For IPM members, this isn’t about abandoning effective promotional techniques. It’s about applying them with greater rigour.

Campaigns should be built on pricing structures that can withstand scrutiny, with clear internal records to evidence “was” prices and promotional timelines. Creative should avoid overstating urgency or exclusivity. And crucially, legal and compliance considerations need to be embedded earlier in the process, before campaigns go live, not after concerns are raised.